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How Many Comparable Sales Are Required?
Here's what the guidelines say: Fannie Mae and VA both require a minimum of three closed sales that have actually been completed and recorded. Fannie Mae allows you to add more sales beyond those three if they help support the appraiser's value opinion, and it even permits using the subject property itself as a fourth comparable if it previously sold. For manufactured homes specifically, HUD/FHA requires at least two comparable sales, though for homes certified under specific programs like MH Advantage, the appraiser should try to find two comparables with that same certification and fill any gap with the best available sales. VA is stricter—it demands the appraiser pick the three best closed comparables available and won't accept listings, contract offers, or unsettled sales to meet that requirement. So the floor is three closed comparables for conventional and VA appraisals, but two for manufactured homes under HUD/FHA rules.
Straight from Fannie Mae Selling Guide, HUD/FHA Single Family Handbook 4000.1, and VA Appraisal Guidelines — nothing added.
Here's what the guidelines say: Fannie Mae and VA both require a minimum of three closed sales that have actually been completed and recorded. Fannie Mae allows you to add more sales beyond those three if they help support the appraiser's value opinion, and it even permits using the subject property itself as a fourth comparable if it previously sold. For manufactured homes specifically, HUD/FHA requires at least two comparable sales, though for homes certified under specific programs like MH Advantage, the appraiser should try to find two comparables with that same certification and fill any gap with the best available sales. VA is stricter—it demands the appraiser pick the three best closed comparables available and won't accept listings, contract offers, or unsettled sales to meet that requirement. So the floor is three closed comparables for conventional and VA appraisals, but two for manufactured homes under HUD/FHA rules.
Straight from Fannie Mae Selling Guide, HUD/FHA Single Family Handbook 4000.1, and VA Appraisal Guidelines — nothing added.
Read the actual documents:
→ Selling Guide Supplement: UAD 3.6 Policy (official agency copy)
→ Handbook 4000.1 Transmittal (2023-01-18) (official agency copy)
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© Copyright Notice: © 2026 Fannie Mae. Excerpts shown for research and reference only. Full document available at selling-guide.fanniemae.com. Reproduction restricted to Fannie Mae-approved lenders.
© Copyright Notice: © Fannie Mae. UAD 3.6 / URAR reference materials shown for research and reference only. Full documents available at fanniemae.com/uad. Reproduction restricted per Fannie Mae copyright policy.
Relevant News
Recent public coverage related to this topic — cited, not reproduced
HUD Deletes Requirement for Original Comparable Photos in FHA Appraisals
HUD eliminated the requirement for appraisers to take original photographs of comparable properties, previously mandated alongside MLS photos for FHA appraisals. This change took effect June 27, 2025.
Read full story at HUD Mortgagee Letter 2025-18 →
HUD Deletes Requirement for Original Comparable Photos in FHA Appraisals
HUD eliminated the requirement for appraisers to take original photographs of comparable properties, previously mandated alongside MLS photos for FHA appraisals. This change took effect June 27, 2025.
Read full story at HUD Mortgagee Letter 2025-18 →
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Fannie Mae September 2026 Page 108 of When describing the proximity of the comparable sale to the subject property, the appraiser must be specific with respect to the distance in…
Fannie Mae Selling Guide · Selling_Guide_Supplement_UAD_3.6_Policy.pdf · Page 108
· View at official source (selling-guide.fanniemae.com) →
· Last verified: 2026-09-30
Fannie Mae September 2026 Page 108 of When describing the proximity of the comparable sale to the subject property, the appraiser must be specific with respect to the distance in terms of miles and include the applicable directional indicator (for example, “1.75 miles NW”). The distance between the subject property and each comparable property is to be measured using a straight line between the properties. Minimum Number of Comparable Sales A minimum of three closed comparables must be reported in the sales comparison approach. Additional comparable sales may be reported to support the opinion of market value provided by the appraiser. The subject property can be used as a fourth comparable sale or as supporting data if it was previously
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Fannie Mae September 2026 Page 107 of SB4-1.3-08, Comparable Sales (09/02/2026) Introduction This topic contains information on selection of comparable sales, including: •…
Fannie Mae Selling Guide · Selling_Guide_Supplement_UAD_3.6_Policy.pdf · Page 107
· View at official source (selling-guide.fanniemae.com) →
· Last verified: 2026-09-30
Fannie Mae September 2026 Page 107 of SB4-1.3-08, Comparable Sales (09/02/2026) Introduction This topic contains information on selection of comparable sales, including: • Selection of Comparable Sales • Minimum Number of Comparable Sales • Age of the Comparable Sales • Additional Requirements for New (or Recently Converted) Condos, Subdivisions, or PUDS • Rural Properties • Use of Foreclosures and Short Sales Selection of Comparable Sales The appraiser is responsible for determining which comparables are the best and most appropriate for the assignment. Fannie Mae expects the appraiser to account for all factors that affect value when completing the analysis. Comparable sales should have same highest and best use and possess similar physical and legal characteristics when compared to the subject
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Sales Comparison Approach Appendix F-1: URAR Reference Guide Page 219 of 375 Version 1.3 General Information The General Information subsection always displays on the sales…
UAD 3.6 / URAR (FNMA) · Appendix F-1 URAR Reference Guide v1.3.pdf · Page 219
· View at official source (fanniemae.com/uad) →
Sales Comparison Approach Appendix F-1: URAR Reference Guide Page 219 of 375 Version 1.3 General Information The General Information subsection always displays on the sales comparison grid. Sales Comparison Approach: General Information Report Field ID Report Label When Row Displays When to Include for each Comparable Allowable Answers / Format Origin of Subject Property Information Adjustable Row Definition / Additional Guidance 22.01.16 Comparable # Always Always required 1, 2, 3 ... Sales Comparable # is only applicable to comparables No Sales Comparable #